November 12, 2012

Preventing penalties: Hazardous waste compliance inspections

In September 2012, the Kansas Department of Health and Environment, or KDHE, visited the main campus to check on our compliance with the Resource Conservation and Recovery Act. This is the act that defines what we consider hazardous waste.

The regulations concerning hazardous waste fall under the jurisdiction of Kansas Department of Health and Environment; however, the U.S. Environmental Protection Agency does not give up the right to inspect us as well. The hazardous waste regulations have been around since 1986 and we have been inspected by the Kansas Department of Health and Environment regularly since that time.

In the mid-1990s the Environmental Protection Agency got very serious with colleges and universities about hazardous waste. Many universities were inspected and penalized for Resource Conservation and Recovery Act violations.

Kansas State University was not immune to penalties. In 1999 we received a Kansas Department of Health and Environment penalty of $29,000. That was followed in 2002 with a visit by the Environmental Protection Agency, which resulted in a penalty of $90,000. In the last two years the University of Kansas, Emporia State University and Pittsburg State University also were inspected and penalized. I am uncertain if our recent Kansas Department of Health and Environment inspection will yield a penalty.

The Division of Public Safety provides a training session monthly that all employees should attend. This training is called “hazardous waste awareness” and consists of a one-hour seminar given in our training room, 011 Edwards Hall.

The schedule for this training can be found at http://www.k-state.edu/safety/safety/training/. We will give you basic knowledge about hazardous and universal waste. Hazardous waste is material you want to discard that has hazardous properties. Universal waste is hazardous waste that can and will be recycled. Universal waste includes mercury products, fluorescent lamps and batteries. Did you know that as an employee of K-State you can drop off your household hazardous waste on campus? Attend a class and learn.

The Division of Public Safety picks up hazardous and universal waste. During these pickups the department also does a cursory inspection of hazardous waste. The inspection consists of looking for the following:

1. Each container of hazardous waste must be labeled with the name of the chemical contents. The name must be the full name, abbreviations or formulas are not acceptable. Actually, all chemical containers must be labeled with the chemical contents.

2. The words “Hazardous Waste” must be on the container.

3. Waste must be kept in the room where the waste was generated. Only one container of each waste type may be stored in the area.

4. When full, the container must be dated and the container must be removed within three days of the date.

5. Waste containers must be kept closed. Actually, all chemical containers must be kept closed. In addition, waste liquids must have secondary containment in case the container leaks.

6. Finally, general housekeeping is assessed and poor housekeeping is considered a violation. Poor housekeeping is generally defined as haphazard and messy laboratory space. As a rule of thumb, if you must move stuff and clean up before a process or experiment can proceed, it is considered poor housekeeping.

To help with keeping the campus in compliance with Resource Conservation and Recovery Act, college environmental health and safety committees are being tasked with inspecting each laboratory and shop for these important requirements. If you have any questions or concerns, feel free to contact me.